A new IRS legal advice memorandum addresses a fact pattern that may become more common in the wake of Tax Reform—sale of intangible property from a controlled foreign corporation to its United States parent—and highlights the...more
6/25/2018
/ Amortization ,
Churning ,
Controlled Foreign Corporations ,
Corporate Branding ,
Foreign Subsidiaries ,
Franchises ,
Intangible Property ,
IP License ,
IRS ,
Multinationals ,
Parent Corporation ,
Tax Reform
In a ruling with tax implications for U.S. corporations with foreign subsidiaries, the U.S. Tax Court has held that transactions between a U.S. parent company and its controlled foreign corporations constitute “United States...more